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Policy
Privacy Policy for Shuffle.us
Last modified: July 2025
This Privacy Policy governs the manner in which Munyon Canyon Limited ("Shuffle.us", "We", "us", or "our"), collects, uses, maintains and discloses information collected from customers of its website www.shuffle.us.
Shuffle.us is committed to protecting and respecting your privacy and maintaining the confidence and trust of its customers. This Privacy Policy explains the types of information we may collect, how your personal information is collected, why it is collected, how it is kept secure, and practices for how it may be disclosed.
Munyon Canyon Limited is responsible for processing the data collected from you using the website www.shuffle.us (“Website”).
This policy applies to information we collect:
On the Website.
In email, text, and other electronic messages between you and this Website.
From the third-party websites through which you connect to our Website ( Facebook, Instagram, Google), or to which you connect when using our Website (Facebook, Instagram, X, Telegram, Google).
It does not apply to information collected by any third party, including through any application or content that may link to or be accessible from or through the Website.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy.
1. Definitions
Personal Information: Any information about you, whether it is true or not, that can reasonably be used to identify you, or otherwise make you identifiable.
Anonymous Information: Information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual.
Aggregate Information: Information about groups or categories of customers, which does not identify and cannot reasonably be used to identify an individual customer.
Shuffle.us ( "Munyon Canyon Limited", "We", "Us" or "Our"): Refers to Munyon Canyon Limited and any applicable subsidiaries or affiliates that form the Shuffle Group and may collect, use, maintain and disclose information collected from the Website as applies to this Privacy Policy.
2. Data Controller
Munyon Canyon Limited is a company incorporated under the laws of the British Virgin Islands, with the register number 2179096 and head office at Trinity Chambers, PO Box 4301, Road Town, Tortola, British Virgin Islands, British Virgin Islands. Munyon Canyon Limited is responsible for processing the data collected from you using the website www.shuffle.us.
3. Minors
Our Website is intended for individuals over the age of majority only (i.e., 18 years old or older, depending on the jurisdiction in which they live). No one under the age of majority may provide any information to or on the Website. We do not knowingly collect personal information from minors. If you are under the age of majority, do not use or provide any information on this Website or through any of its features, register on the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a minor, we will delete that information. If you believe we might have any information from or about a minor, please contact us at [email protected].
4. Jurisdictional Statement
The Shuffle Group of which Shuffle.us is an affiliate operates in several international jurisdictions and Personal Information we collect may be transferred to, and stored and processed by, individual companies in the Shuffle Group or by third parties in the European Union, the United States, Canada, Australia, or any other country in which our third-party processors maintain facilities. We will ensure that transfers of Personal Information to any country or organization are subject to appropriate safeguards and legal requirements.
5. Policy Updates
This Privacy Policy may be updated from time to time to reflect changes in the way we work or the way our work is regulated. We will notify you of material changes and, where required by law, will obtain your consent. Notice may be by the posting of such changes on our website or by other means in accordance with applicable law. The date the privacy policy was last revised is identified at the top of the page. Any changes to the Privacy Policy will become effective when the updated policy is posted on www.shuffle.us. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the Personal Information we collect. Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so pleas check the policy periodically for updates.
6. Type of Information We Collect
We collect three types of information: Personal Information, Anonymous Information, and Aggregated Information. Any other information that we receive and identify as your Personal Information will be treated as Personal Information by Shuffle.us.
The types of Information we may process depend on the business context and the purposes for which it was collected. It may include:
Contact Details, such as your first name and surname, email address, residential address, and mobile or other phone numbers.
Personal Information, such as gender, age, age range or your image.
Unique personal identifier attributed from your username, email address, mobile or other phone number(s) and/or residential address.
Account login details, including your username, password and pictures associated with your profile.
Transaction Information you provide when you make a purchase, request a redemption or otherwise use the Website, such as your postal address, phone number and payment or redemption information including banking and financial details, credit card details and bank account statements (we do not store your full card details).
Geolocation Information, including approximate location information provided by a mobile or other device interacting with the Website, or associated with your IP address, where we are permitted by law to process this information.
Usage Data, which may include activity, technical and device information about your use of the Website, such as the content you view, the time and duration of your visit on our Website, how often you use our services, how you first heard about our Website, your preferences and information about your interaction with the content offered through our Website, your hardware model, device type, other unique device identifiers, operating system version, browser type and IP address.
Sensitive Information, which may include government issued identity (including drivers licenses, passport and social security numbers), geolocation and financial information to comply with our business, legal and regulatory purposes.
Information we obtain from a third party, such as a site or platform provider (including Facebook and Google), about your use of or interest in our services.
Identification documents (may include ID, utility bills, bank statements, etc.).
Communications exchange with our teams (support, live chat, complaints, etc.).
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
7. Information Collection Table
Information Category | What this contains | We Capture this Information |
Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, or other similar identifiers. | YES |
Personal Information | Including but not limited to name, signature, social security number, physical characteristics or description, communications such e-mails or chat messages, address, telephone number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. | YES |
Protected Classification characteristics under California or federal law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
Biometric Information | An individual's physiological, biological or behavioral characteristics that can be used singly or in combination with each other or with other identifying data, to establish individual Identity. Facial recognition technology collects information from your image capture, including biometric data, and shares this information with us, which assists us to verify your ID. | YES |
Internet or other similar network activity | Browse history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES |
Geolocation data | Physical or IP address location or movements. | YES |
Sensory data | Audio, electronic, visual, or similar information. | YES |
Professional or employment-related information | Current or past job history. | YES |
Non-public education information | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
Inferences drawn from other personal information | Profile reflecting a person's preferences, characteristics, predispositions, behaviour. | YES |
Government Identifiers | Social security, driver's license or state identification card. | YES |
Complete account access credentials | Customer names, account numbers, digital currency addresses, or card numbers combined with required access/security code or password. | YES |
Precise Geolocation | Precise physical or IP address location or movements. | YES |
Racial or ethnic origin | Racial or ethnic origin information that may be revealed through Government or other identifiers or other personal information. | YES |
Religious or philosophical beliefs |
| NO |
Union membership |
| NO |
Genetic data |
| NO |
Mail, email or text messages content not directed to us | Chat conversations conducted on our platform; communications with our affiliates or service providers. | YES |
Unique identifying biometric information | Biometric information that may be revealed through Government or other identifiers or other personal information. | YES |
Health, sex life, or sexual orientation information |
| NO |
8. Sources of Information
We obtain the categories of personal information listed above from the following sources:
Directly from our customers. For example, when customers register for our services or respond to requests for information verification.
Directly and indirectly from activity on our websites and applications – such collections occur automatically as you navigate through and interact with our Website. This includes:
Usage and log information. For example, service-related, diagnostic and performance information. This includes information about your activity on our websites and applications, log files and reports.
Device and connection information. We collect device-specific information such as hardware model, operating system information, browser information, IP address etc.
From third-parties that interact with us in connection with the services we perform. We may work with third-parties such as Facebook or Instagram, for example, in order to understand, customise, provide, support and market the services we provide and/or to comply with laws.
The technologies we use for automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For information about managing privacy and security setting for cookies, see Use of Personal Information and Sharing of Personal Information.
Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
9. Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications on the Website are served by third-parties, including content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Use of Personal Information and Sharing of Personal Information.
10. Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
To present our Website and its contents to you
To provide and manage the information, products or services you that you request from us
To maintain, develop, and improve customer service and our services
To create, maintain, customize, and secure your customer account
To fulfil purchases or redemptions and prevent transactional fraud
To personalize and customize our Website and your user experience according to your individual interests
To contact you about our services or the services of our partners, including marketing communications and communications sent jointly with our partners
To send important notices to you, including notices regarding changes to our Website or any products or services we offer or provide through it
To fulfil any other purpose for which you provide it
To allow you to participate in interactive features on our Website
To help us improve our Website and to deliver better and more personalized services, including enabling us to estimate our audience size and usage patterns, store information and recognize you when you return to our Website
To comply with our legal and regulatory obligations
To offer alternative dispute resolution services
In any other way we may describe when you provide the information
For any other purpose with your consent or as permitted by law.
We will not retain the categories of personal information and sensitive personal information longer than reasonably necessary to achieve these business purposes. Ordinarily, we will retain your personal information and sensitive personal information for up to 12 months beyond any closure of your account, unless a longer retention period is required or permitted by law.
11. Sharing or Disclosure of Personal Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose your personal information that we collect or you provide as described in this document:
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Munyon Canyon Limited’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Munyon Canyon Limited about our Website users is among the assets transferred.
To fulfil the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
As otherwise permitted by law.
We may also disclose your personal information:
To comply with any court order, law, or legal process, including responding to any government or regulatory request.
To enforce or apply our Terms and Conditions and other agreements, including for billing.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Munyon Canyon Limited, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
The categories of personal information we may disclose include:
Category of personal information | Example |
General personal data | Full name, sex, personal identification code or number, date of birth, legal capacity, nationality and citizenship, location (street, city, country, and postcode). |
Identity document data | Document type, issuing country, number, expiry date, MRZ, information embedded into document barcodes (may vary depending on the document), security features. |
Facial image data | Photos of the face (including selfie images) and photos or scans of the face on the identification document, videos, and sound recordings. |
Biometrical data | Facial features |
Banking details | Cardholder name, expiry date, first 6 and last 4 digits of the card number |
Contact details | Address, e-mail address, and phone number |
Data concerning health | ID number of COVID passport, date of issuance of the passport, name, date of birth, test result |
Transaction data | Full name of the sender and the recipient, the address of the sender and the recipient, and the Unique identifier of the counterparties provided by Sumsub and the particular Client |
Crypto transaction data (Crypto Travel Rule Solution and Wallet Address Book) | Full name of the sender and the recipient, the physical (geographical) address of the sender, or national identity number, or customer identification number (i.e., not a transaction number) that uniquely identifies the originator to the ordering institution, or date and place of birth, recipient account number (e.g., wallet address), wallet address hash, asset, chain, dates of creation and update, VASP ID owner, source type, source provider, client ID |
Technical data | Information regarding the date, time, and activity in the Services; IP address and domain name; software and hardware attributes (e.g., camera name and type); general geographic location (e.g., city, country) from User’s device. |
Geolocation data | IP address |
Unique identifier | Applicant ID created only for identifying the User in the Sumsub system |
Relevant publicly available data | Information regarding a person’s status as a Politically Exposed Person (PEP) or presence on sanctions lists |
Additional information | Data provided by the User during communication with Sumsub (e.g., requests, reports) |
Device behavioural data | User ID, device fingerprint data (screen size, user agent, browser, incognito mode, type of device, operating system, geolocation), screen resolution, session languages, operating system verification, focus/blur of the window, time of the day, focus in/out, paste, mouse movement, battery usage to detect emulator, detect touch/mouse/keystroke events, G meter/AccelMeter |
We do not sell your personal information or share it with third-parties for cross-context behavioral advertising that is not at least co-branded.
12. Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us.
Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-out at any time by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase or other transactions.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
13. Exercising Access, Correction, and Deletion Rights
You can review and change your personal information by logging into the Website and visiting your account profile page.
To request access to, correction of, or deletion of your personal information, you may also submit a verifiable consumer request to us at [email protected].
If you decide to use an authorized agent, please also include written permission that you have designated that agent to make this request, or proof of the agent's power of attorney. We may follow up with you to verify your identity before processing your authorized agent's request.
For your consumer request to be verifiable, you must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. You will need to provide:
Full name
Date of birth
Address
E-mail address
If you would like to know the specific pieces of personal information that we have collected about you, or to delete your personal information, identification that clearly shows your name, date of birth and address (for example, driver's license or other photo identification)
Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
14. Response Timing and Format
We endeavor to provide timely responses to verifiable consumer request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.
The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
15. Your State Privacy Rights
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. For instance, California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Note that we do NOT share personal information with third parties (that are not members of the Shuffle Group)
for this purpose.
16. Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
17. Non-Discrimination
We will not discriminate against you for exercising any of your rights described above.
18. Contact Information
If you have specific questions regarding your Personal Information, how we process or use it, or to exercise your rights, please contact our Privacy Team directly by email at [email protected].
